SEC Comment Letter for BIO KEY INTERNATIONAL INC (BKYI) (CIK 0001019034) (BKYI) — Jan 6, 2017
BIO KEY INTERNATIONAL INC (BKYI) (CIK 0001019034)
Date: Jan. 6, 2017 · CIK: 0001019034 · Accession: 0000000000-17-000654
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-203613, 333-214792
Letter
Mail Stop 4561 January 6, 2017 Michael W. DePasquale Chief Executive Officer BIO-key International, Inc. 3349 Highway 138, Building A, Suite E Wall, NJ 07719
Re: BIO-key International, Inc. Amendment No. 1 to Registration Statement on Form S-1 Filed December 23, 2016 File No. 333-214792 Amendment No. 1 to Post-Effective Amendment No. 1 to Registration Statement on Form S -1 Filed December 23, 2016 File No. 333-203613
Dear Mr. DePasquale:
We have reviewed your amended registration statement and post-effective amendment and have the following comment.
Please respond to this letter by amending your filings and providing the requested information. If y ou do not believe our comment appl ies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment s to your filings and the information you provide in response to our comment, we may have additional comments.
Registration Statement on Form S -1 (File No. 333 -214792)
Executive Compensation, page 30
1. Please update your executive compensation disclosure to provide the information called for by Item 402 of Regulation S -K for your fiscal year ended December 31, 201 6. For guidance, please refer to Question 117.05 of our Regulation S -K Compliance and Disclosure Interpretations. Please add corresponding disclosure in your post -effective amendment.
Michael W. DePasquale BIO-key International, Inc. January 6, 2017 Page 2
You may contact Jeff Kaute n, Staff Attorney, at (202) 551 -3447 or, in his absence, me at (202) 551 -3457 with any questions.
Sincerely,
/s/ Maryse Mills -Apenteng
Show Raw Text
Mail Stop 4561 January 6, 2017 Michael W. DePasquale Chief Executive Officer BIO-key International, Inc. 3349 Highway 138, Building A, Suite E Wall, NJ 07719 Re: BIO-key International, Inc. Amendment No. 1 to Registration Statement on Form S-1 Filed December 23, 2016 File No. 333-214792 Amendment No. 1 to Post-Effective Amendment No. 1 to Registration Statement on Form S -1 Filed December 23, 2016 File No. 333-203613 Dear Mr. DePasquale: We have reviewed your amended registration statement and post-effective amendment and have the following comment. Please respond to this letter by amending your filings and providing the requested information. If y ou do not believe our comment appl ies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment s to your filings and the information you provide in response to our comment, we may have additional comments. Registration Statement on Form S -1 (File No. 333 -214792) Executive Compensation, page 30 1. Please update your executive compensation disclosure to provide the information called for by Item 402 of Regulation S -K for your fiscal year ended December 31, 201 6. For guidance, please refer to Question 117.05 of our Regulation S -K Compliance and Disclosure Interpretations. Please add corresponding disclosure in your post -effective amendment. Michael W. DePasquale BIO-key International, Inc. January 6, 2017 Page 2 You may contact Jeff Kaute n, Staff Attorney, at (202) 551 -3447 or, in his absence, me at (202) 551 -3457 with any questions. Sincerely, /s/ Maryse Mills -Apenteng Maryse Mills -Apenteng Special Counsel Office of Information Technologies and Services cc: Vincent A. Vietti , Esq. Fox Rothschild LLP